Income Tax Issues
Deductions

San Jose Wellness v. Commissioner (156 T.C. No. 4)

On February 17, 2021, the Tax Court issued its opinion in San Jose Wellness v. Commissioner, 156 T.C. No. 4. The underlying issue presented in San Jose Wellness was whether the petitioner, a marijuana dispensary, was prohibited from claiming deductions for depreciation and charitable contributions under IRC § 280E. Background The petitioner operated a medical marijuana dispensary pursuant to California law from 2010 to 2015. It sold marijuana to individuals who held a valid doctor’s

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Bad Debt Losses

Franklin v. Commissioner (T.C. Memo. 2020-127)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct certain business losses.

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Income Tax Issues
IRC § 162

Brashear v. Commissioner (T.C. Memo. 2020-122)

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business).

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Badges of Fraud

Collins v. Commissioner (T.C. Memo. 2020-50)

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the petitioners are liable for additions to tax for failing to timely file their returns; and whether petitioner-husband is liable for the civil fraud penalty of

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Income Tax Issues
Books and Records

Williams v. Commissioner (T.C. Memo. 2020-48)

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2020-48). The primary issue before the court in Williams was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses of the petitioner-husband’s new business venture as he grew it and prior to the business’ actual operation.

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Income Tax Issues
Deductibility of Expenses

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a).

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Income Tax Issues
Books and Records

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when the employee had a right to seek reimbursement from his employer.

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San Jose Wellness v. Commissioner (156 T.C. No. 4)

On February 17, 2021, the Tax Court issued its opinion in San Jose Wellness v. Commissioner, 156 T.C. No. 4. The underlying issue presented in San Jose Wellness was whether the petitioner, a marijuana dispensary, was prohibited from claiming deductions for depreciation and charitable contributions under IRC § 280E. Background

Read More »

Franklin v. Commissioner (T.C. Memo. 2020-127)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct

Read More »

Brashear v. Commissioner (T.C. Memo. 2020-122)

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business).

Read More »

Collins v. Commissioner (T.C. Memo. 2020-50)

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the

Read More »

Williams v. Commissioner (T.C. Memo. 2020-48)

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2020-48). The primary issue before the court in Williams was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses of the

Read More »

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a).

Read More »

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when

Read More »